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Firm Brochure
(Part 2A of Form ADV)
1853 William Penn Way
Suite 14
Lancaster, PA 17601
This brochure provides information about the qualifications and business
practices of Adare Asset Management, LLC. From time-to-time, we may refer to
the document as the “Brochure.” If you have any questions about the contents of
the Brochure, please contact us at: 717-203-2844 or by e-mail at:
tim@adareasset.com. The information in the Brochure has not been approved or
verified by the United States Securities and Exchange Commission, or by any
state securities authority.
Additional information about Adare Asset Management, LLC is available for
review on the SEC’s website at www.adviserinfo.sec.gov. Registration with the
SEC and/or other state securities commissions does not imply a certain level of
skill or training.
February 26, 2026
Material Changes
Annual Update
The Material Changes section of this Brochure will be updated annually, and also
promptly whenever material changes occur.
Material Changes since the Last Update
The U.S. Securities and Exchange Commission (“SEC”) issued a rule in July 2010
requiring advisers like Adare Asset Management, LLC (“Adare”) to prepare a
Brochure for clients and prospective clients that is drafted using “plain English.” The
new rule also specifies mandatory sections and organization for the Brochure.
The last annual updating amendment of Adare Asset Management, LLC was on
03/14/2025. Material changes relate to Adare Asset Management, LLC’s policies,
practices or conflicts of interests.
• Adare Asset Management, LLC has updated its assets under management.
Full Brochure Available
Whenever you would like to receive a complete copy of our Brochure, please contact
Timothy N. Deery by telephone at: 717-203-2844 or by email at:
tim@adareasset.com.
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Table of Contents
Contents
Material Changes .............................................................................................................. i
Annual Update .............................................................................................................. i
Material Changes since the Last Update......................................................................... i
Advisory Business ............................................................................................................ 1
Firm Description .......................................................................................................... 1
Types of Advisory Services ........................................................................................... 1
Tailored Relationships .................................................................................................. 2
Wrap Fee Programs ..................................................................................................... 2
Client Assets ................................................................................................................. 2
Fees and Compensation .................................................................................................... 2
Description ................................................................................................................... 2
Payment of Selection of Other Advisers Fees ................................................................. 2
Subadviser Services Fees .............................................................................................. 3
Fee Billing .................................................................................................................... 3
Payment of Selection of Other Advisers Fees ................................................................. 3
Payment of Subadviser Fees .......................................................................................... 3
Performance-Based Fees .................................................................................................. 4
Sharing of Capital Gains .............................................................................................. 4
Types of Clients ............................................................................................................... 4
Description ................................................................................................................... 4
Methods of Analysis, Investment Strategies and Risk of Loss ............................................ 4
Methods of Analysis & Investment Strategies ................................................................ 4
Risk of Loss .................................................................................................................. 5
Disciplinary Information .................................................................................................. 6
Legal and Disciplinary .................................................................................................. 6
Other Financial Industry Activities and Affiliations .......................................................... 6
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 6
Code of Ethics .............................................................................................................. 6
Participation or Interest in Client Transactions & Personal Trading ............................. 6
Brokerage Practices ......................................................................................................... 7
Selecting Brokerage Firms & Soft Dollars ..................................................................... 7
Review of Accounts .......................................................................................................... 8
Periodic Reviews .......................................................................................................... 8
Review Triggers ........................................................................................................... 8
Regular Reports ........................................................................................................... 8
Client Referrals and Other Compensation ........................................................................ 8
Incoming Referrals ....................................................................................................... 8
Referrals Out ............................................................................................................... 9
Other Compensation .................................................................................................... 9
Custody ........................................................................................................................... 9
Account Statements ...................................................................................................... 9
Reports ........................................................................................................................ 9
Technical Definition of Custody .................................................................................... 9
Investment Discretion ...................................................................................................... 9
Discretionary Authority for Trading ............................................................................. 9
Limited Power of Attorney ......................................................................................... 10
Voting Client Securities .................................................................................................. 10
Proxy Votes ................................................................................................................ 10
Financial Information .................................................................................................... 11
Financial Condition .................................................................................................... 11
Bankruptcy Petitions in Previous Ten Years ............................................................... 11
Advisory Business
Firm Description
Adare Asset Management, LLC is an investment adviser located in Lancaster, PA.
Adare commenced operations in December of 2009. The owner of Adare is Timothy
N. Deery.
Types of Advisory Services
Adare provides continuous investment management based on the individual needs of
the client on either a discretionary or non-discretionary basis. We manage individual
portfolios of bonds, stocks, mutual funds and exchange traded funds with limited
exposure to other investments such as options.
Our basic strategy for investing in equities utilizes a conservative approach without
excessive turnover in portfolios. Important factors are sustainable and growing
profits and/or strong dividend payouts. We also look for companies that have strong
management teams and are positioned to take advantage of their position in their
marketplace.
Adare takes a very conservative approach to bond investing. For our clients, we
invest in individual bonds that are of extremely high quality, as designated by the
major rating agencies in the United States. We invest in both taxable and tax-free
bonds, determined by the requirements and needs of each client.
Adare also specializes in the analysis and selection of financial services companies
such as banks, insurance companies and diversified financial companies. For a select
number of clients, we manage portfolios consisting only of these securities. This
particular style portfolio typically experiences more turnover due to the nature of the
industry. Often, equity positions in small capitalization companies are utilized and
therefore require a nimbler approach to buying and selling.
Adare may direct clients to third-party investment advisers. Before selecting other
advisers for clients, Adare will always ensure those other advisers are properly
licensed or registered as investment adviser.
Prior to introducing Pennsylvania clients to another investment adviser (“IA”), Adare
will be responsible for determining whether the investment advisory firm is properly
licensed, notice filed, or exempt from registration with the Pennsylvania Department
of Banking and Securities.
Adare may also act as a subadviser to advisers unaffiliated with Adare. These
third-party advisers such would outsource portfolio management services to Adare.
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This relationship will be memorialized in each contract between Adare and the
third-party advisor.
Tailored Relationships
Adare believes investing should be based on each client’s individual needs and goals.
For example, we generally feel it would be improper to have identical investments for
a retired couple of 80 and a working professional of 45. It’s for that reason that
Adare tailors portfolios to meet the needs of each client. At times, that can mean
investing in more dividend oriented stocks for those with current income needs or
investing in higher growth companies for those with very long time horizons.
Additionally, clients occasionally place restrictions on their investment accounts,
such as the type of investments they are willing to own or their unwillingness to sell a
large position in a stock with a low cost basis. We build each portfolio to fit the
needs of the client.
Wrap Fee Programs
Adare does not participate in wrap fee programs.
Client Assets
As of December 2025, Adare managed $151,263,255.00 on discretionary client assets
and $8,038,419.00 on non-discretionary client assets.
Fees and Compensation
Description
Adare charges fees based on the size or value of the account. The standard fee is
1.00% on the value of the account. We negotiate fees based on a number of factors
which include size of account, required meeting schedule and complexity of the
investment strategy implemented.
Payment of Selection of Other Advisers Fees
Adare may direct clients to third-party investment advisers. Adare will be compensated
via a fee share from the advisers to which it directs those clients. This relationship will
be memorialized in each contract between Adare and each third-party adviser. The fees
shared will not exceed any limit imposed by any regulatory agency. The notice of
termination requirement and payment of fees for third-party investment advisers will
depend on the specific third-party adviser selected.
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Total client fees will not exceed 3% of assets under management when a third-party
investment adviser is used.
Subadviser Services Fees
Adare may also act as a subadviser to unaffiliated third-party advisers. Adare would
receive a share of the fees collected from the third-party adviser’s client. The fees
charged will not exceed any limit imposed by any regulatory agency. This
relationship will be memorialized in each contract between Adare and the third-party
adviser.
Fee Billing
Fees can either be deducted from client accounts or billed directly to the client.
Clients may select either method. Clients are billed monthly or quarterly either in
advance or arrears and advised in writing at the beginning of the relationship that they
may terminate our services on any quarterly billing date. Clients may terminate an
agreement in writing with 10 days’ notice. Should a relationship terminate during a
quarterly period, clients may obtain a refund. The refund will be prorated based on
the number of days the account was managed during the quarter in which the
relationship was terminated.
Payment of Selection of Other Advisers Fees
The timing, frequency, and method of paying fees for selection of third-party
managers will depend on the specific third-party adviser selected and will be
disclosed to the client prior to entering into a relationship with the third-party advisor.
Fees for selection of Maguire Investments, LLC. are withdrawn directly from the
client’s accounts with client’s written authorization or may be invoiced and billed
directly to the client and clients may select the method in which they are billed. Fees
are paid quarterly in advance.
Payment of Subadviser Fees
Subadviser fees may be withdrawn from client’s accounts or clients may be invoiced
for such fees, as disclosed in each contract between Adare and the applicable
third-party adviser.
We will obtain client written authorization and send the qualified custodian written
notice of the amount of the fee to be deducted from the client account.
There will also be an itemized invoice sent to the client including any formulae used
to calculate the fee, the time period covered by the fee, and the amount of assets
under management on which the fee was based. If a client is not given a copy of the
firm brochure at least 48 hours prior to signing an agreement or contract, the client
has five business days in which to cancel the contract, without penalty.
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In addition to Adare’s management fees, clients pay commissions or transaction fees
to their broker or custodian, along with exchange fees. Certain accounts, such as trust
accounts that require a corporate trustee, incur a custody fee, while standard
brokerage account is typically free from custody fees. Mutual funds often charge
multiple fees, including management fees and general expenses of the fund. This fee
is charged on top of the Adare fee for services. For additional information, please
see page 6 regarding brokerage practices.
Adare and its supervised persons do not accept compensation for the sale of
securities.
Performance-Based Fees
Sharing of Capital Gains
Adare does not use a performance-based fee structure. Performance-based
compensation may create an incentive for the adviser to recommend an investment
that may carry a higher degree of risk to the client.
Types of Clients
Description
Adare provides investment advice to individuals, trusts, estates, charitable
organizations, banks, and pension and profit sharing plans.
Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis & Investment Strategies
Adare uses multiple methods to analyze potential investments including fundamental,
technical and cyclical or trend analysis.
Our fundamental analysis relies heavily on the review of a potential investment’s
financial statements. Adare focuses on earnings both from a nominal level and
relative to previous periods. At that point, the firm relates perceived earnings power
to the price of the stock in the marketplace. That price/earnings ratio plays a key role
in determining whether a stock is trading above or below fair value. Dividend policy
and book value also play a role in determining the correct price for a stock.
Our technical analysis plays a relatively small role in determining whether to
purchase or sell a stock. Rather, it is used as a timing indicator in order to avoid
buying or selling at a weak point for any particular stock.
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Adare’s cyclical or trend analysis plays a key role in discovering companies that
previously were undiscovered or have been left behind due to previous poor
performance. The firm continuously analyzes the economy and looks for growing
trends or cyclical changes that favor certain industries. This process produces a list of
companies that potentially suit client portfolios, assuming they pass the fundamental
test as well.
Risk of Loss
All investment programs have certain risks that the investor will bear. Adare’s
investment approach keeps the risk of loss in mind. Clients face the following
investment risks:
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Interest-rate Risk: Fluctuations in interest rates may cause investment prices
to fluctuate. For example, when interest rates rise, yields on existing bonds
become less attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of risk is
caused by external factors independent of a security’s particular underlying
circumstances. For example, political, economic and social conditions may
trigger market events.
•
Inflation Risk: When any type of inflation is present, a dollar today will not
buy as much as a dollar next year, because purchasing power is eroding at the
rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value
of the dollar against the currency of the investment’s originating country.
This is also referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments
may have to be reinvested at a potentially lower rate of return (i.e. interest
rate). This primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a
particular company within an industry. For example, oil-drilling companies
depend on finding oil and then refining it, a lengthy process, before they can
generate a profit. They carry a higher risk of profitability than an electric
company, which generates its income from a steady stream of customers who
buy electricity no matter what the economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into
cash. Generally, assets are more liquid if many traders are interested in a
standardized product. For example, Treasury Bills are highly liquid, while
real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the terms of
its obligations in good times and bad. During periods of financial stress, the
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inability to meet loan obligations may result in bankruptcy and/or a declining
market value.
Disciplinary Information
Legal and Disciplinary
Neither Adare nor anyone employed by it have been involved in legal or disciplinary
events related to past or present investment clients.
Other Financial Industry Activities and Affiliations
Adare and its management persons have no other financial industry activities and
affiliations.
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics
Adare has adopted a code of ethics requiring all personnel associated with the
company to act as fiduciaries solely in the best interest of its clients. The code sets
out principles to be followed and obligations of all those associated with the
company. Copies of our Code of Ethics are available by calling Timothy N. Deery at
717-203-2844 or by writing him at 1853 William Penn Way, Suite 14, Lancaster, PA
17601.
Participation or Interest in Client Transactions & Personal Trading
With respect to personal transactions, employees and other related persons, from time
to time, will be buying and selling securities recommended to clients. Employees are
permitted to effect transactions at the same time and in a manner consistent or
inconsistent with transactions being executed in client accounts, without pre-
clearance, as long as the securities traded are not listed on Adare’s restricted list at the
time of the transaction. Employees are restricted from trading securities on Adare’s
restricted list for their own accounts without prior authorization to prevent the
potential for conflict of interest. Securities that are not restricted include those that
are highly liquid, publicly traded and/or with market capitalizations of more than $1
billion. Securities that do not meet these criteria will not necessarily be restricted if
they are not being actively traded for client accounts.
All access persons are required to file annual holdings reports and quarterly
transaction reports for reportable securities. Additionally, we have procedures in
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place to monitor personal trading to determine with reasonable assurance compliance
with these provisions.
Brokerage Practices
Selecting Brokerage Firms & Soft Dollars
When recommending brokers to clients for client transactions, Adare considers
multiple factors. We select brokers based on some specialized expertise or access to
securities with limited supply (municipal bonds as an example) that are generally not
available through all brokers simultaneously. When selecting a brokerage firm, one
may consider a number of factors, including but not limited to:
• The nature of the security being traded;
• The size and type of the transaction;
• The nature and character of the markets for the security to be
purchased or sold;
• The desired timing of the trade;
• The activity existing and expected in the market for the particular
security;
• Confidentiality, including trade anonymity;
• The quality of the execution, clearance and settlement services;
• Financial stability of the broker-dealer; and
• The broker-dealers execution capabilities, including block
positioning, and ability to obtain best price and execution.
Adare recommends Fidelity Brokerage Services LLC and HBW, Inc.
We do not participate in any soft dollar arrangements, whereby we would receive a
benefit in return for trading with a certain broker. We also do not receive referrals
from brokers in exchange for commissions. For those reasons, there is no conflict of
interest when we recommend any broker to a client.
While we do not require clients to direct us to use specific brokers, clients often
request or require we use their preferred broker for custody and/or trading of their
account. When this occurs, we explain to the client the potential for additional costs
related to using their preferred broker. This is often as a result of higher commissions
either because their preferred broker does not offer as competitive a rate or because
we don’t have the ability to aggregate their orders with those of other clients, which
can reduce commission rates. We generally do not make undirected attempts to
negotiate commission rates.
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We aggregate orders, when possible, to reduce transaction costs to our clients.
Typically, we are buying and selling the same securities for our clients with similar
investment objectives. By aggregating the orders, we can reduce the commission
paid by each client.
Review of Accounts
Periodic Reviews
Adare performs reviews of all accounts under its management to ensure that the
various client portfolio structures are in line with the client's investment objectives.
Investment policy is reviewed and individual securities are analyzed in the light of
current economic and financial reports. Portfolio changes are then considered.
Review Triggers
Other conditions that may trigger a review are unforeseen changes in the marketplace,
changes in investment information and changes in a client's policies or investment
situation. Changes in client accounts may be implemented at any time, if appropriate
to the client's situation, subject to constraints placed upon Adare by the client.
Regular Reports
Clients will receive quarterly portfolio valuation statements. These statements
include the amount of each security held, its original cost, the cost price and current
price of the security, its current value, its percent of the total portfolio value, and the
current yield of that security. The statements divide the portfolio into various bond
and stock categories, as well as a total valuation for the entire account.
Monthly reports provided by the client’s custodian (not Adare), give detailed
information such as change in the account’s value vs. the previous month, current
value of all account holdings, and a detailed transaction history for the reporting
period.
No client statements are issued for consulting services.
Client Referrals and Other Compensation
Incoming Referrals
Adare has been fortunate to receive occasional client referrals. The referrals came
from current clients, business professionals, and other similar sources. We do not
compensate referring parties for these referrals.
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Referrals Out
Adare does not accept referral fees or any form of remuneration from other
professionals when a prospect or client is referred to them.
Other Compensation
Adare receives no compensation not discussed in earlier sections of the Brochure.
Custody
Account Statements
Adare is deemed to have “limited” custody when its fees are directly debited by a
qualified custodian. Adare will not have the authority to withdraw client funds, nor
will it serve as custodian of any client funds or securities. All assets are held at
qualified custodians, which mean the custodians provide account statements directly
to clients at their address of record at least quarterly.
Reports
Clients are urged to compare the account statements received directly from their
custodians to the additional statements provided by Adare.
Technical Definition of Custody
There is one circumstance in which we will be considered to have “custody” as
defined by the SEC. We may submit invoices for the payment of Adare Investment
Supervisory, or Advisory Fees to custodians if the client has specifically authorized
those custodians to deduct those fees from the account and to pay those fees directly
to us. The authority to submit fee invoices to the custodian for payment meets the
technical definition of “custody” of funds as defined by the SEC.
Investment Discretion
Discretionary Authority for Trading
Clients may grant discretionary authority to Adare to manage securities accounts.
Discretionary authority means that we have the authority to determine, without
obtaining specific client consent, the securities to be bought or sold, and the amount
of the securities to be bought or sold. This authority is carried out in a way consistent
with the investment policy that the client has approved in writing.
We also accept client relationships which require prior client approval of trades (non-
discretionary).
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Limited Power of Attorney
Adare’s discretionary clients sign a discretionary agreement granting us limited
power of attorney. That agreement gives us the authority to buy, sell, exchange and
trade in stocks, bonds and any other securities selected by Adare for the benefit of the
client.
Voting Client Securities
Proxy Votes
Adare does not vote proxies unless explicitly requested to do so by the client. If
explicitly requested to do so, we will act in a manner which we deem prudent and
diligent and which is intended to enhance the economic value of the securities held in
client accounts. We have adopted a written Proxy Voting Policy, which details
general voting positions with respect to specific governance issue and corporate
actions. These voting positions are grouped into five categories. The categories and
associated guidelines are as follows:
Election of Board of Directors - Adare will generally vote in support of
management's nominees for the board of directors; however, we may choose not to
support management's proposed board if circumstances warrant such consideration.
Appointment of Independent Auditors - Adare will support the recommendation of
the respective corporation's board of directors.
Issues of Corporate Structure and Shareholder Rights - Proposals may originate
from either management or shareholders, and among other things, may request
revisions to the corporate bylaws that will affect shareholder ownership rights. We
do not generally support obstacles erected by corporations to prevent mergers or
takeovers with the view that such actions may depress the corporation's marketplace
value. We support the following types of corporate structure and shareholder rights
proposals:
• Management proposals for approval of stock repurchase programs;
stock splits (including reverse splits).
• Authorization to increase shares outstanding.
• The ability of shareholders to vote on shareholders rights plans (poison
pills).
• Shareholders rights to eliminate or remove supermajority provisions.
• Shareholders' rights to call special meetings and to act by written
consent.
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Executive and Director Equity-Based Compensation - Adare is generally in favor
of properly constructed equity-based compensation arrangements. We will support
proposals that provide management with the ability to implement compensation
arrangements that are both fair and competitive. However, we may oppose
management proposals that could significantly dilute shareholders' ownership
interests in the corporation.
Corporate Social and Policy Issues - Proposals usually originate from shareholders
and may require a revision of certain business practices and policies. Adare believes,
however, that typical business matters that directly or indirectly affect corporate
profitability are primarily the responsibility of management. Therefore, social and
policy issues reflected in shareholder proposals should be subject to the approval of
the corporation's board of directors.
We may engage the services of an independent third party ("Proxy Firm"). It may
vote proxies individually for an account or in the aggregate and may record votes
across a group of accounts, strategy or product. In addition, we may refrain from
voting a proxy on behalf of client accounts in certain situations such as de minimis
holdings, certain items relating to foreign issuers, timing issues related to opening
and/or closing of accounts, and contractual arrangements with clients and/or their
authorized delegate.
In the rare instance when we do vote proxies, we discuss with the client the
possibility that conflicts of interest could arise in connection with that proxy voting.
Adare will provide a copy of the Proxy Voting Policy upon request and without
charge. We will also provide to any client, upon request and without charge,
information regarding how proxies for their securities were voted, if they have
explicitly requested us to vote for them.
Financial Information
Financial Condition
Adare does not have any financial impairment that will preclude the firm from
meeting contractual commitments to clients.
A balance sheet is not required to be provided because we do not serve as a custodian
for client funds or securities, and we do not require prepayment of fees of more than
$1200 per client, and six months or more in advance.
Bankruptcy Petitions in Previous Ten Years
Adare has not been the subject of a bankruptcy petition in the last ten years.
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